MEMORANDUM. SUBJECT: NFPA 69 Proposed Tentative Interim Amendment (TIA) No.1212

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National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 Fax: 617-770-0700 www.nfpa.org MEMORANDUM TO: FROM: Technical Committee on Explosion Protection Systems Laura Montville, Staff Liaison DATE: December 15, 2015 SUBJECT: NFPA 69 Proposed Tentative Interim Amendment (TIA) No.1212 The attached proposed Tentative Interim Amendment (TIA) is being submitted to you for letter ballot. This proposed TIA was submitted by Martin Clouthier, Clouthier Risk Engineering and endorsed by Sam Rogers, Honeywell, Inc. This proposed TIA will be published for public comment in the January 8, 2016 issue of NFPA News with a Public Comment Closing Date of February 19, 2016. Any public comments received will be circulated to the committee. The Standards Council will consider the issuance of this TIA at the next scheduled Council meeting on April 5-6, 2016. In accordance with Section 5 of the Regulations Governing the Development of NFPA Standards, you are being balloted on the technical merits of the proposed TIA and whether this matter is of an emergency nature. Please complete and return your ballot as soon as possible but no later than Monday, December 28, 2015. As noted on the ballot form, please return the ballot to Diane Matthews either via e-mail to dmatthews@nfpa.org or via fax to 617-984-7110. You may also mail your ballot to the attention of Diane Matthews at NFPA, 1 Batterymarch Park, Quincy, MA 02169. Note: Please remember that the return of ballots and attendance at committee meetings are required in accordance with the Regulations Governing the Development of NFPA Standards.

TECHNICAL COMMITTEE LETTER BALLOT PROPOSED TENTATIVE INTERIM AMENDMENT LOG NO. 1212 To add a new Annex B.8 of the 2014 Edition of NFPA 69, Standard on Explosion Prevention Systems Question No. 1: I agree with the TECHNICAL MERITS of the Proposed TIA to add a new Annex B.8. AGREE DISAGREE* ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation shall accompany a disagree or abstain vote. Question No. 2: I agree that the subject is of an EMERGENCY NATURE. AGREE DISAGREE* ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation shall accompany a disagree or abstain vote. Signature Name (Please Print) Date Please return the ballot on or before Monday, December 28, 2015. PLEASE RETURN TO: Diane Matthews, Project Administrator NFPA 1 Batterymarch Park Quincy, MA 02169 FAX: (617) 984-7110 E-mail: dmatthews@nfpa.org

NFPA 69-2014 Edition Standard on Explosion Prevention Systems TIA Log No.: 1212 Reference: Annex B.8 (new) Comment Closing Date: February 19, 2016 Submitter: Martin Clouthier, Clouthier Risk Engineering 1. Add a new Annex B.8 to read as follows: B.8 Limiting Oxygen Concentration for Fuel Mixtures. The limiting oxidant concentration (LOC) for a fuel mixture can be estimated based on the relationship that the LOC is approximately equal to the LFL multiplied by the stoichiometric oxygen ratio, S. The approximation LOC = LFL x S is usually conservative because it assumes the LOC occurs at the LFL concentration of the fuel. Two types of calculations can be performed to estimate the LOC for fuel mixtures. First, if only LFL data are available, the LOC of the mixture can be calculated from the mixture LFL. Second, if LOC data are available for the mixture components, a calculation can be performed for the LOC of the mixture. When performing the second type of calculation manually, as opposed to using a spreadsheet, it is better to do it in parts to avoid errors. The LOC estimation method is not applicable for diluents other than nitrogen because the diluent must have a very similar heat capacity to the oxygen and nitrogen components present at the LFL. Similar to the considerations with regard to methane enrichment of vent collection headers in 7.7.3, the LOC estimation method is not recommended for mixtures containing components with a UFL greater than 75 mol% in air. Such gases typically have UFLs in oxygen greater than 90 mol%, and in some cases the upper LOC value might be less than the lower LOC value (Kuchta, 1985) [1]. Furthermore, this method is not recommended for mixtures containing a decomposable gas or a gas that might be decomposable at elevated temperature and pressure. B.8.1 Method 1 Estimating Mixture LOC from Known Component LFLs. This method starts with known component LFLs (either determined by experiment or by using a reliable method) and uses Le Chatelier s rule to estimate the LFL for the mixture. The stoichiometric oxygen ratio for the mixture is calculated. The results of both calculations are used to estimate the LOC for the mixture. Step 1: Calculate LFL of mixture using Le Chatelier s rule: Equation B.8.1(a) where xi is the mole fraction of component i having LFL = Li (mol%) in mixture.

Step 2: Calculate stoichiometric oxygen Si needed for each mixture component i. Let CcHhOoNnXx = some arbitrary gas (where X represents Cl or other halogen). Equating coefficients in the stoichiometric combustion equation gives the following: Equation B.8.1(b) Then S = moles of oxygen are needed for stoichiometric combustion; hence Equation B.8.1(c) Step 3: Calculate stoichiometric oxygen Smix. The mathematical expression for this calculation is the following: Equation B.8.1(d) Step 4: Calculate the limiting oxygen concentration of the mixture LOCmix. Assume the LOC is equal to the minimum concentration of oxygen needed to completely combust the LFL concentration of fuel: LOCmix = LFLmix x Smix B.8.1(e) Example 1 Calculate LFL for a mixture containing 0.20 mole methane, 0.40 mole methanol, 0.30 mole methylamine, and 0.10 mole methyl chloride. Using reported LFL data from Britton and Frurip [2], as shown in Table 1:

Hence Following Steps 1 through 3, calculate LOCmix: LOCmix = LFLmix x Smix = 5.59 x 1.825 = 10.2 mol% O2 B.8.2 Method 2 Estimating Mixture LOC from Known Component LOCs. This approach was presented by Zlochower and Green [3] and starts with known component LOC data and then assumes the LOC is equal to the stoichiometric ratio S times a derived fuel concentration (or pseudo LFL) at limiting oxidant concentration, L * i. The fuel mixture flammable limit is implicit in the solution, which results in a weighted average of the LOCs of the components. The pseudo LFL at the LOC is B.8.2(a) where LOCi is the LOC for component i. The mixture LOC is the product of the derived mixture fuel concentration and the mixture molar average stoichiometric ratio.

B.8.2(b) The derived mixture fuel concentration from Le Chatelier s rule is as follows: The LOC of the mixture is as follows: B.8.2(c) B.8.2(d) Example 2 Consider a fuel mixture consisting of methane, ethylene, carbon monoxide, and methanol, with the mole fractions and component LOCs in nitrogen [3, 4] as summarized in Table 3. The stoichiometric ratios for each component and the intermediate values from Equation (B.8.2d) are summarized in Table 4. The LOC of the mixture is calculated using Equation (B.8.2d) is as follows:

B.8.3 References for B.8. [1] J. M. Kuchta, Bulletin 680, U.S. Bureau of Mines, Pittsburgh, PA, 1985. [2] L. G. Britton and D. J. Frurip, Further Uses of the Heat of Oxidation in Chemical Hazard Assessment, Process Saf. Prog. 22 (2003), no. 1, 1 19. [3] I. A. Zlochower and G. M. Green, The Limiting Oxygen Concentration and Flammability Limits of Gases and Gas Mixtures, J. Loss Prev. Process Ind. 22 (2009), no. 4, 499 505. [4] H. F. Coward and G. W. Jones, Limits of Flammability of Gases and Vapors, Technical Report 503, U.S. Bureau of Mines, 1952. Substantiation: This second TIA provides users with a simple method for estimating the LOCs of single gases and gas mixtures based on the equation LOC = LFL x S, where LFL is the lower flammable limit and S the molar stoichiometric ratio of oxygen to fuel. Furthermore, NFPA 69 does not offer any guidance for users on estimating the LOC for mixtures. The consequence of not providing such guidance is that users are forced to assume the LOC for the lowest mixture component, which means more inert gas will be required than necessary. Emergency Nature: Justification for the emergency nature of the proposed TIAs is based on Section 5.3, Item (f) of the Regulations Governing the Development of NFPA Standards: (f) The proposed TIA intends to correct a circumstance in which the revised document has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process, or was without adequate technical (safety) justification for the action. Furthermore, this proposed TIA would provide users a method to determine the LOC of mixtures. We therefore propose two Tentative Interim Amendments (TIAs). This second TIA describes a technique for estimating LOC values from LFL values, plus worked examples showing how to estimate LOCs of gas mixtures starting either from measured LOC or LFL values. The detailed TIA is presented here. This TIA Provides new annex material which offers guidance and example calculations on how to estimate the LOC for a fuel or a fuel mixture using established methods. The method is only applicable for nitrogen diluent and is not presently recommended for mixtures containing any component with a UFL greater than 75 mol% in air. The LOC estimation method in this TIA is not applicable for diluents other than nitrogen because the diluent must have a very similar heat capacity to the oxygen and nitrogen components present at the LFL. The approximation represented by LOC = LFL x S assumes that

the heat capacity stays approximately constant as diluent gas is added to the mixture of fuel and oxidant that defines the LFL. The LOC estimation method in this TIA is not presently recommended for mixtures containing components with a UFL greater than 75 mol% in air. Such gases typically have UFLs in oxygen greater than 90 mol% and in some cases the upper LOC value might be less than the lower LOC value. This problem might be academic owing to various practical limits on the composition of the gas mixture. Another possible factor is the presence either of decomposable gases or gases with high reported UFLs that might become decomposable at elevated temperatures and pressures. NFPA 69 previously considered this issue with respect to the methane enrichment of vent collection headers and decided that, in the absence of specific data, it would be prudent to limit general use of the method to gases whose UFL in air is no larger than that of hydrogen (75 mol%).

Foran, Rosanne From: Sent: To: Cc: Subject: Rodgers, Sam (Process Safety) <samuel.rodgers@honeywell.com> Wednesday, November 18, 2015 12:08 PM Montville, Laura Larry Britton (l.britton@suddenlink.net); Martin Clouthier; TIAs RE: NFPA 69 TIAs Concerning Limiting Oxygen Concentrations Laura, I endorse these TIAs. Sam Rodgers From: Montville, Laura [mailto:lmontville@nfpa.org] Sent: Wednesday, November 18, 2015 12:06 PM To: Larry Britton (l.britton@suddenlink.net); Rodgers, Sam (Process Safety) Cc: Martin Clouthier; TIAs Subject: RE: NFPA 69 TIAs Concerning Limiting Oxygen Concentrations Sam and Larry, We need a written statement that at least one of you are endorsing the processing of this TIA. Please reply to this email (copying TIAs_Errata_FIs@nfpa.org) if you do endorse the TIA. Thank you, Laura Laura Montville Engineer NFPA 1 Batterymarch Park Quincy, MA 02169 617 984 7496 lmontville@nfpa.org NFPA's "Project Holiday" can help you and your community stay fire safe. From: Martin Clouthier [mailto:mclouthier@crefire.ca] Sent: Wednesday, November 18, 2015 10:07 AM To: Montville, Laura <LMontville@nfpa.org>; TIAs <TIAs_Errata_FIs@nfpa.org> Cc: Larry Floyd <mobilefloyd@yahoo.com>; Larry Britton (l.britton@suddenlink.net) <l.britton@suddenlink.net>; 1

'Rodgers, Sam (Process Safety)' <samuel.rodgers@honeywell.com> Subject: NFPA 69 TIAs Concerning Limiting Oxygen Concentrations Please see attached proposed TIAs to NFPA 69, concerning limiting oxygen concentrations. This submittal is co sponsored by technical committee members Sam Rodgers and Larry Britton (nonvoting member). Regards, Martin P. CLOUTHIER, MSc, PEng Principal Consulting Engineer Clouthier Risk Engineering Ltd. +1 (902) 444 0207 mclouthier@crefire.ca http://crefire.ca 2